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Energy Efficient Products

Are separate control gears that are embedded in the control board of an appliance considered as ‘Components and subassemblies’ ?

According to Article 2.2 of the Ecodesign Directive 2009/125/EC, ‘Components and  subassemblies’ are not in scope of Ecodesign legislation. 

Separate Control Gears (SCGs) embedded in a multifunctional control board of an appliance can be qualified as components or sub-assemblies within the meaning of Article 2(2) of the Ecodesign Directive if these are (i) intended to be incorporated into products and (ii) are not placed on the market and/or put into service as individual parts for end -users or if their environmental performance cannot be assessed independently.

The SCGs concerned are intended to be placed in inter alia home appliances. Their environmental performance cannot be assessed independently but only together with the home appliance. The SCGs concerned meet the definition of components/sub-assemblies under the Ecodesign Directive. The SCGs concerned therefore do not fall within the scope of the Commission Regulation (EU) 2019/2020.

Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.